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HomeMy WebLinkAbout13-2188 Supreme Co _ nnsylvania COu : C0 %ullb , leas For Prothonotary Use Only: ?, ,p � lt d. l I� vet' dt Docket No: CU t M J� County The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service of pleadings or other papers as required by law or rules of court. Commencement of Action: S 19 Complaint ® Writ of Summons n Petition © Transfer from Another Jurisdiction ® Declaration of Taking E C Lead Plaintiff's Name: Lead Defendant's Name: WEST SHORE COUNTRY CLUB LISA M. BROSIUS T Dollar Amount Requested: within arbitration limits I Are money damages requested? Yes 13 No (check one O ) ®outside arbitration limits N Is this a Class Action Suit? ® Yes El No Is this an MDJAppeal? © Yes 0 No ' A Name of Plaintiff /Appellant's Attorney: Robert D. Kodak, Esquire ! Check here if you have no attorney (are a Self-Represented 1Pro Se] Litigant) Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS ® Intentional ® Buyer Plaintiff Administrative Agencies ® Malicious Prosecution ® Debt Collection: Credit Card ® Board of Assessment ® Motor Vehicle xi Debt Collection: Other [3 Board of Elections Nuisance Goods & Services Provided ® Dept. of Transportation ® Premises Liability ril Statutory Appeal: Other S ® Product Liability (does not include ® Employment Dispute: E mass tort) ® Slander/Libel /Defamation Discrimination El O C M Other: © Employment Dispute: Other 0 Zoning Board T , [3 Other: I Other: O MASS TORT Asbestos N ® Tobacco Toxic Tort -DES ® Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS © Toxic Waste Other: E3 Ejectment 12 Common Law /Statutory Arbitration B ® Eminent Domain /Condemnation 0 Declaratory Judgment 0 Ground Rent n Mandamus 0 Landlord/Tenant Dispute ® Non - Domestic Relations Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY © Mortgage Foreclosure: Commercial © Quo Warranto Q Dental © Partition [3 Replevin Legal 13 Quiet Title n Other: n Medical Other: r ® Other Professional: Updated 1/112011 FILEO-O F ICE Ot4 ", THE- PROTHONOTAFjy 2013 APR 22 P11 1: 12 CUMBERLAND COUNTY ROBERT D. KODAK, ESQUIRE PENNSYLVANIA KODAK LAW OFFICES, P.C. 407 N FRONT STREET, PO BOX 11848 J ���� HARRISBURG, PA 17108 -1848 1 (717) 238 -7159 Attorney for Plaintiff WEST SHORE COUNTRY CLUB, ` IN THE COURT OF COMMON PLEAS OF .Plaintiff •' CUMBERLAND COUNTY, PENNSYLVANIA v NO. LISA M. BROSIUS, Defendant(s) •' CIVIL ACTION - LAW NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by an attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE PA 17013 717- 249 -3166 Cof 03 g°�7� AVIso LISTED HA SIDO DEMANDADO /A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dias despues de la notificacion de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparencencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES ' POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE PA 17013 717- 249 -3166 WEST SHORE COUNTRY CLUB, '•. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v NO. LISA M. BROSIUS, Defendant(s) CIVIL ACTION - LAW COMPLAINT The Plaintiff, WEST SHORE COUNTRY CLUB, by its attorneys, KODAK LAW OFFICES, P.C., brings this action of Assumpsit against the Defendant(s) to recover the sum of FOUR THOUSAND TWO HUNDRED THIRTY FOUR DOLLARS AND EIGHTY EIGHT CENTS ($4,234.88), along with interest thereon at the statutory rate of 6% from February 1, 2013, upon a cause of action of which the following is a statement: 1. The Plaintiff, WEST SHORE COUNTRY CLUB, is a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, having its principal office and place of business at 100 Brentwater Road, Camp Hill, Pennsylvania 17011 -2099. 2. The Defendant, LISA M. BROSIUS, is an adult individual residing at 326 N. 25 T " STREET, CAMP HILL, CUMBERLAND COUNTY, PENNSYLVANIA 17011. F:\USER\Z MASTER CMP FILES\ W\ WEST SHORE COUNTRY CLUB\ WEST SHORE COUNTRY CLUB 38909.wpd 2 3. On or about June 15, 2009 Defendant, Lisa M. Brosius, submitted a Membership Application to Plaintiff, on behalf of "and her family. A full family membership was granted to Defendant, . a true and correct copy of which is attached hereto, marked Exhibit "A" and made a part hereof. 4. On the dates, in the amounts, and for the prices set forth in a true and correct copy of the Plaintiff's Statement of Account hereto attached, marked Exhibit "B" and made a part hereof, Plaintiff, at the special instance request of the Defendant(s), sold and delivered goods, wares and merchandise of the kind and description set forth on said Exhibit and /or performed labor and provided services of the kind and description set forth on said Exhibit to the total amount of Four Thousand Two Hundred Thirty Four Dollars and Eighty Eight Cents ($4,234.88). 5. The prices charged for said goods, wares and merchandise and /or labor performed or services provided, were just and reasonable, were the legal and market prices therefor and were the prices which the Defendant(s) promised and agreed to pay to Plaintiff. 6. The balance due and owing by Defendant(s) to Plaintiff is the sum of Four Thousand Two Hundred Thirty Four Dollars and Eighty Eight Cents ($4,234.88), as appears by Plaintiff's Statement of Account hereto attached, marked as Exhibit "B" and made a part hereto. F: \USER \Z MASTER CMP FILES\ W\ WEST SHORE COUNTRY CLUB\ WEST SHORE COUNTRY CLUB 38909.wpd 3 7. Plaintiff's Invoices are not attached to this pleading due to the voluminous nature of same and have previously been provided to Defendant(s). 8. Plaintiff frequently demanded payment from Defendant(s) of said amount due and owing as aforesaid, but Defendant(s) refused and neglected and still refuse(s) and neglect(s) to pay said amount or any part thereof. WHEREFORE, Plaintiff brings this suit to recover from Defendant(s) the sum of FOUR THOUSAND TWO HUNDRED THIRTY FOUR DOLLARS AND EIGHTY EIGHT CENTS ($4,234.88) together with interest as set forth herein. Respectfully submitted, KODAK LAW OFFICES, P.C. 53964 D. Kodak, Esquire ID# 18041 407 North Front Street Post Office Box #11848 Harrisburg, PA 17108 -1848 (717) 238 -7159 Attorney for Plaintiff F:\USER\Z MASTER CMP FILES\ W\ WEST SHORE COUNTRY CLUB\ WEST SHORE COUNTRY CLUB 38909.wpd 4 PROPOSAL FOR MEMBERSHIP Please supply the following confidential information: Check One: Active Social ( Junior Legacy: Yes L No Current USGA Member Yes No Date: y ne vs a 0� Social Security: Name: �..-\ `�a (� C > �b 1 0 S, Spouse Name: Home Address: 0 3 ST, Home Phone: AV PR lIL Email: Firm: Type of Business: S 1q v'1 - Q0 V Position: _C% How Long? Office Address: c�, f J�, Office Phone: CGY`n�� �` \t ` Fax: Date of.Birth: Birthplac e: Spouse's Date of Birth Birthplace: Education: (optional) Gc�nz)a\ t P-5 CQ r, Spouse Education: (optional) Number of Children: Children's Interest: Swim Team Jr. Golf [) Tennis Name: Date of Birth. I Name: Date of Birth: L Name: Date of Birth: M Q FL) L) Name: Date of Birth: M ❑ F Your Hobbies: Spouse's Hobbies: Club Interests: Spouse Golf Social Events Tennis Q Swinumng This proposal must be MAILED or DELIVERED to: SECRETARY — WEST SHORE COUNTRY CLUB 100 BRENTWATER ROAD CAMP HILL, PA 17011 Phone: (717) 761 -4530 www.westshorecc.rom A check payable to West Shore Country Club covering the applicable entrance fee must accompany this proposal. J Q W W J Q J J Q Candidate is well acquainted with the following Members of the West Shore Country Club who are authorized to furnish the Membership Committee with any pertinent information concerning applicant. Proposed by ame - Printed Iil i Signature (Active Member) Seconded by _ Or, '�;+'0 aa� tX U1 Name - Printed Signa (Active Member) Seconded by 4 D�'. �Lo o S N-.4w A jftm�� Name - Printed Si tore (Active Member) I agree to abide by the By -Laws and regulation of the West Shore Country Club. I further authorize and agree that a personal background check and /or credit information may be obtained and used in evaluating my application_ . Signature of Candidate Address for Newsletters 3 3 cr - t' -\ and Notices cav\ Q V NNA V PR 4 I C b Address for Billing (if different from above) DO NOT ATE BELOW THIS LINE Date Received by Membership Committee Date Posted Date Approved by Membership Committee Date Approved by Board Date Membership Effective House Charges: 1,056.38 " Dues: 2,712.10 Total Due: 3,768.48 Lj 4 (- 1 4 0 Ms Lisa M Brosius 01131/2013 B2010 LA 326 N. 25th Street a �� Camp Hill, PA 17011 TER Termination January 01, 2013 " BEGINNING BALANCE (62010 Ms Lisa M Brosius). 1,05fi.38 TOTAL: 0.00 0.00 0.00 0.00 1,056.38 BEGINNING BALANCE (Dues) 2,712.10 TOTAL: 0.00 0.00 0.00 0.00 2,712.10 r" We are still offering direct debit to your checking account as a means of paylrig your monthly statement If you wish to enroll, or have questions, please call-the office. Go ' s bY� �nbran FP-e_ . Due Date for this Billing is January 31st 2013 0.00 0:00 0.00 721.99 3,046.49 a 3,768.48 0 J F H N J J Q VERIFICATION (name) ' (title) ' of West Shore Country.Club , verify that the statements made in the aforegoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 .Pa. C. S. §4904, relating to unsworn falsification to authorities. WES HORE COUNTRY LUB By. Title: Dated: 38909/ B 2010 BROSIUS C'n , SHERIFF'S OFFICE OF CUMBERLAND COUNTY x) r - r- Ronny R Anderson r r— ire tior of aaaGeq NSheriff � 7 cD Jody S Smith fi�t D a* r Chief Deputy . . •:,s, ;- ;f , > t Richard W Stewart -- ,''' Solicitor =� Ex,-= -< C3 ..y<_a West Shore Country Club Case Number vs. Lisa M Brosius 2013-2188 SHERIFF'S RETURN OF SERVICE 04/25/2013 03:24 PM- Deputy Tim Black, being duly sworn according to law, served the requested Complaint& Notice by"personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Lisa M Brosius at 326 N. 25th Street, Camp Hill Borough, Camp Hill, PA 17011. NYp- 7'f---_--- TI LACK, DEPUTY SHERIFF COST: $45.41 SO ANSWERS, I9._ ‘ ."'" April 29, 2013 RONNYR ANDERSON, SHERIFF -i+U^ 1. ;n^f r re.i CSC" WEST SHORE COUNTRY CLUB IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v NO. 2013-2188 CIVIL LISA M. BROSIUS Defendant(s) CIVIL ACTION - LAW `0 TO: PROTHONOTARY,COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PRAECIPE FOR DEFAULT JUDGMENT , ca Enter judgment in favor of Plaintiff and against Defendant(s), LISA M. BROSIUS, named for failure to file within the required time an Answer to the Complaint in the above-captioned case and assess the Plaintiff's damages as follows: Amount claimed in Plaintiff's Complaint . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . $ 4,234.88 Interest at the rate of 6% per annum from 2/1/13-6/4/13(0.70 per diem) . . . . $ 86.10 Less payments, if any . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . $ 0.00 TOTAL . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . $ 4,320.98 PLUS: court costs and accruing interest . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . $ TBD I hereby certify that a written Important Notice of the intent to file this Praecipe was mailed or delivered to the Defendant(s) and/or his/her Attorney of Record,if any;after the default occurred and at least ten (10) days prior to the date of the filing of this Praecipe and a copy of the notice(s) is/are attached. C�Cv�}�`lic•SOp� KODAK LAW OFFICES, P.C. e kµ q�u By st * 1�o��e JEFF TROUTMAN Attorney for Plaintiff �1e. DATED: Judgment a ered d d es assess s above. Prothonotary c > WEST SHORE COUNTRY CLUB, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v NO. 13-2188 Civil LISA M. BROSIUS, Defendant(s) CIVIL ACTION -LAW IMPORTANT NOTICE / AVISO IMPORTANTE TO/ A: LISA M. BROSIUS Defendant(s) / Defendido(s) DATE OF NOTICE / FECHA DEL AVISO: May 28, 2013 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. ............................................................................................................................................................................................................................................. USTED ESTA EN REBELDIA PORQUE HA FALLADO DE REGISTRAR COMPARENCENCIA ESCRITA POR SI MISMO O A TRAVES DE UN ABOGADO Y SOMETER CON LA CORTE SUS DEFENSAS U OBJECCIONES A LOS CARGOS QUE SE HAN PRESENTADO CONTRA USTED. A MENOS QUE USTED ACTUE DENTRO DE DIEZ DIAS DE HABER RECIBIDO ESTE AVISO, LA CORTE PUEDE TOMAR UNA DECISION EN CONTRA SUYA SIN TENER DERECHOS A UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTA DOCUMENTO A SU ABOGADO INMEDIATEMENTE. SI USTED NO TIENE UN ABOGADO, LLA.ME O VAYA A LA SIGUIENTE OFICINA. ESTA. OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE PA 17013 717-249-3166 ' KODAK LAW OFFICES, P.C. CAMERON MANSION Telephone Robert D.Kodak 407 NORTH FRONT STREET 717.238.7159 x101 Jeffrey L.Troutman POST OFFICE BOX 11848 Facsimile HARRISBURG,PA 17108-1848 717.238.7158 May 28, 2013 et? rpm LISA M BROSIUS RLE 326 N 25TH STREET CAMP HILL PA 17011 RE: West Shore Country Club VS: Lisa M. Brosius No. 13-2188 Civil, Court of Common Pleas, Cumberland County, PA Our File No. 38909 Greetings: In accordance with Pennsylvania Rules of Civil Procedure 237.1(a)(2),we are enclosing herewith a Notice of a Praecipe for Entry of Default Judgment. According to the records as they are found in the Office of the Prothonotary of Cumberland County, you have not filed responsive pleadings to the Complaint filed against you to the above term and number,nor has any attorney entered an appearance on your behalf. Accordingly,we are forwarding to you the enclosed Notice which indicates that if you do not take action as set forth in this Notice, we, at the expiration of time indicated therein, will request the Office of the Prothonotary of Cumberland County to enter Judgment against you in the amount as set forth in said Complaint. Very truly yours, KODAK LAW OFFICES,P.C. J "9).Xldu ROBERT D. KODAK, ESQUIRE rkodak @kodaklaw.com RDK/akr Enclosures THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT COLLECTOR. c FRANK NESTLER WEST SHORE COUNTRY CLUB 100 BRENTWATER ROAD CAMP HILL PA 17011 B2010 WEST SHORE COUNTRY CLUB •'. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v NO. 2013-2188 CIVIL LISA M. BROSIUS Defendant(s) CIVIL ACTION -LAW TO/A: LISA M. BROSIUS Defendant(s) / Defendido/a, Defendidos/as You are hereby notified that on U e 2013 the following Judgment has been entered against you in the above-captioned case. Por este medio se le esta notificando que el de del 2013 el/la siguiente(Fallo) ha sido anotado en contra suya en el caso me cion eirnpigrafe. Date: Fecha : Prothonotary / Protonotario judgment entered in the amount of $4,320.98 I hereby certify that the name and address of the proper person(s) to receive this notice is: LISA M. BROSIUS 326 N 25TH STREET CAMP HILL PA 17011 Attorney for Plaintiff Abogado del Demandante PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENTS) P.R.C.P. 3101 to 3149 WEST SHORE COUNTRY CLUB VS LISA M. BROSIUS 314 c)Ci6 CCM OM PA Plaintiff DEFENDANT(S) c101k IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA Writ No. Term 20 No. 2013-2188 Amount Due 6/6/13 jdmt 4,320.98 Interest from jdmt to 3/28/14 $0.71 per diem 209.54 Atty's Commission 5% statutory rate $ 216.05 Costs (t� be determined) TO THE PROTHONOTARY OF SAID COURT: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER, (1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania (2) against LISA M. BROSIUS (3) and against e ertaant(s); 271 (4) and index this writ (a) against LISA M. BROSIUS (b) against <tJ --; -earnis.fteTe(s )• F3'17 -4., Defendant(s) and as a lis pendens against the real property of the defendant(s) in the name of the Garnishee(s) as follows: (Specifically describe property and note any specific direction to Sheriff) Furnish 4 copies for real estate levy): Garnishee(s), LEVY UPON ALL PERSONAL PROPERTY OF THE ABOVE-LISTED DEFENDANT(S) AT THE ABOVE ADDRESS IN CUMBERLAND COUNTY, INCLUDING BUT NOT LIMITED TO FURNITURE, JEWELRY, ELECTRONICS, SUPPLIES, ETC., Exemption has (not) been waived. t-L)q,(_-t eSF 1( " ilvso " 11H. y . Troutman, Esquire Robert D. Kodak, Esquire 407 N. Front - 3' Floor Harrisburg, PA 17101 (717) 238-7159 ?. 2S -out 4. Attorneys For Plaintiff(s) i1 C CrJ x C H Z Sf1ISOIIfl 'N VSI1 D 1C?IINIlOD HNOHS o rD 5 N NOTE Under paragraph (1) when the writ is directed to the sheriff of another county as authorized by Rule 3103(b), the county should'be indicated. Under Rule 3103(c) a writ issued on a transferred judgment may be directed only to the sheriff of the county in which issued. Paragraph (3) (above should be completed only in a named garnishee is to be included in the writ). Paragraph (4)(a) should be completed only if indexing of the executions in the county of insurance, is desired as authorized by Rule 3104(a), When the writ issues to another county indexing is required as of course in that county by the prothonotary. See Rule 3I04(b). Paragraph (4)(b) should be completed only if real property in the name, 9f the garnishee is attached and indexing as a lis pendens is desired. See Rule 3104(c). THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net WEST SHORE COUNTRY CLUB Vs. LISA M. BROSIUS WRIT OF EXECUTION (Pa R.C.P. 3252) NO 13-2188 Civil Term CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against LISA M. BROSIUS, 326 NORTH 25TH STREET, CAMP HILL, PA 17011 Defendant (s) (1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein; LEVY UPON ALL PERSONAL PROPERTY OF THE ABOVE-LISTED DEFENDANT(S) AT THE ABOVE ADDRESS IN CUMBERLAND COUNTY, INCLUDING BUT NOT LIMITED TO FURNITURE, JEWELRY, ELECTRONICS, SUPPLIES, ETC. (2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of GARNISHEE(S), as garnishee, (Specifically describe property) and to notify, the garnishee that (a) an attachment has been issued; (b) except as provided in paragraph (c), the garnishee is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (c) the attachment shall not include (1) the first $10,000 of each account of the defendant (s) with a bank or other financial institution containing any funds which are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (ii) each account of the defendant (s) with a bank or other financial institution in which funds on deposit exceed $10,000.00 at any time if all funds are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (iii) any funds in an account of the defendant (s) with a bank or other financial institution that total $300 or less. If multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as determined by the executing officer. The funds shall be set aside pursuant to the defendant (s) general exemption provided in 42 Pa.C.S. § 8123. (3) if property of the defendant (s) not levied upon and subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify such other person that he or she has been added as a garnishee and is enjoined as above stated. Amount Due $4,320.98 Plaintiff Paid Interest FROM JUDGMENT TO 3/28/14 $0.71 PER DIEM - $209.54 Law Library $.50 Attorney's Comm. 5 % STATUTORY RATE - $216.05 Due Prothonotary $2.25 Attorney Paid $194.16 Other Costs Date: 4/2/14 David D. Buell, Prothonotary Deputy REQUESTING PARTY: Name : JEFFREY L. TROUTMAN, ESQUIRE Address: KODAK LAW OFFICES, P.C. 407 NORTH FRONT STREET 3R1) FLOOR HARRISBURG, PA 17108 Attorney for: PLAINTIFF Telephone: 717-238-7159 Supreme Court ID No, MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain insurance proceeds 8. Such other exemptions as may be provided by law 2 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OF THE PROTHOHO;A 1' 20114 APR 24 PM 3 20 CUMBERLAND COUNTY PENNSYLVANIA oi�:n+rr�ica West Shore Country Club vs. Lisa M Brosius Case Number 2013 -2188 SHERIFF'S RETURN OF SERVICE 04/08/2014 08:10 PM - Deputies went to address provided; per current homeowners, defendant was the previous owner. 04/24/2014 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned STAYED. Defendant has moved out of Cumberland County to 801 W Siddonsburg Road, Dillsburg, PA 17019, which is located in York County. SHERIFF COST: $64.45 SO ANSWERS, April 24, 2014 RONNY R ANDERSON, SHERIFF c) Cou^tvSUte Sheriff, s ele, Off, PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENTS) P.R.C.P. 3101 to 3149 WEST SHORE COUNTRY CLUB Plaintiff vs IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA Writ No. Term 20 No. 2013-2188 Amount Due LISA M. BROSIUS 6/6/13 jdmt $ 4,320.98 801 W SIDDONSBURG RD Interest from jdmt to 5/8/14 DILLSBURG PA 17019 $0.71 per diem $ 238.66 DEFENDANT(S) Atty's Commission 5% statutory rate $ 216.05 Costs (to be determined) TO THE PROTHONOTARY OF SAID COURT: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER, (1) Directed to the Sheriff of YORK County, Pennsylvania (2) against LISA M. BROSIUS (3) and against (4) and index this writ (a) against LISA M. BROSIUS (b) against efendant(s); --< r7 n- u) r` a a Defendant(s) and Garnishee(s), as a lis pendens against the real property of the defendant(s) in the name of the Garnishee(s) as follows: (Specifically describe property and note any specific direction to Sheriff) Furnish 4 copies for real estate levy): LEVY UPON ALL PERSONAL PROPERTY OF THE ABOVE -LISTED DEFENDANT(S) AT THE ABOVE ADDRESS IN YORK COUNTY, INCLUDING BUT NOT LIMITED TO FURNITURE, JEWELRY, ELECTRONICS, SUPPLIES, ETC., A (5) Exemption has (not) been waived. 4,a8 5o pa Ally '15.LI1 CBr &4. 45 re L. Troutman, Esquire 103.75 f Robert D. Kodak, Esquire I(o. 50 " 407 N. Front - 3`d Floor as, 60 14 Harrisburg, PA 17101 (717) 238-7159 Dated 5/8/14 4 (WI. II PD frrrY Attorneys For Plaintiff(s) a.a5Ne CO altaizEito ,f30k633 (,Ori1-cF THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net WEST SHORE COUNTRY CLUB Vs. NO 13-2188 Civil Term CIVIL ACTION — LAW LISA M. BROSIUS WRIT OF EXECUTION (Pa R.C.P. 3252) TO THE SHERIFF OF YORK COUNTY: To satisfy the judgment, interest and costs against LISA M. BROSIUS, 801 W. SIDDONSBURG ROAD, DILLSBURG, PA 17019 Defendant (s) (1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein; LEVY UPON ALL PERSONAL PROPERTY OF THE ABOVE -LISTED DEFENDANT(S) AT THE ABOVE ADDRESS IN YORK COUNTY, INCLUDING BUT NOT LIMITED TO FURNITURE, JEWELRY, ELECTRONICS, SUPPLIES, ETC.. (2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of GARNISHEE(S), as garnishee, (Specifically describe property) and to notify the garnishee that (a) an attachment has been issued; (b) except as provided in paragraph (c), the garnishee is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (c) the attachment shall not include (i) the first $10,000 of each account of the defendant (s) with a bank or other financial institution containing any funds which are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (ii) each account of the defendant (s) with a bank or other financial institution in which funds on deposit exceed $10,000.00 at any time if'alI funds are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (iii) any funds in an account of the defendant (s) with a bank or other financial institution that total $300 or less. If multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as determined by the executing officer. The funds shall be set aside pursuant to the defendant (s) general exemption provided in 42 Pa.C.S. § 8123. 1 (3) if property of the defendant (s) not levied upon and subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify such other person that he or she has been added as a garnishee and is enjoined as above stated. Amount Due $4,320.98 Plaintiff Paid. Interest FROM JDMT TO 5/8/14 - $.71 PER DIEM - $238.66 Law Library Attorney's Comm. 5 % STATUTORY RATE - $216.05 Due Prothonotary $2.25 Attorney Paid $287.11 Other Costs Date: 5/30/14 (Sea( i David D. Buell, Prothonotary B REQUESTING PARTY: Name : JEFFREY L. TROUTMAN, ESQUIRE Address: KODAK LAW OFFICES, P.C. 407 NORTH FRONT STREET, 3RD FLOOR HARRISBURG, PA 17101 Attorney for: PLAINTIFF Telephone: 717-238-7159 Supreme Court ID No. MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW I. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain insurance proceeds 8. Such other exemptions as may be provided by law 2 SHERIFF'S OFFICE OF YORK COUNTY Richard P Keuerleber ��� o PETER J. MANGAN, ESQ. Sheriff a` Solicitor Michael S. Hose Richard E Rice,II 1i 0. ( 3 �I rjij Chief Deputy, Administration Chief Deputy, Operations WEST SHORE COUNTRY CLUB vs. LISA M. BROSIUS Case Number 2014 -SU -2119-41 SHERIFF'S RETURN OF SERVICE 06/26/2014 RECEIVED $5048.02 (INTO ESCROW) FROM DEFENDANT TO SETTLE AND SATISFY JUDGMENT DEBT AND COSTS ON WRIT. ISSUED ESCROW CHECK #91361 IN THE AMOUNT OF $4891.75TO ROBERT D. KODAK, ESQ., ATTORNEY FOR THE PLAINTIFF TO SETTLE AND SATISFY JUDGMENT DEBT AND COSTS OF EXECUTION. . 06!26!201 10:15 AM - SERVED ONE TRUE AND ATTESTED COPY OF THE WITHIN WRIT OF EXECUTION AND CLAIM FOR EXEMPTION FORM UPON LISA M. BROSIUS, THE WITHIN NAMED DEFENDANT AT 801 WEST SIDDONSBURG ROAD, DILLSBURG, PA 17019, INFORMED DEFENDANT OF CONTENTS OF SAME. SHERIFF COST: $156.27 (PAID BY DEFENDANT) TAYLOR E K, DEPUTY 74NSWRS, • June 30, 2014 RICHARD P K TERLEBER, SHERIFF COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sheila E. Cook, Notary Public City of York, York County My Commission Expires Feb. 1, 2017 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES r-rl NOTARY Affirmed and subscribed to before me this 30TH day of JUNE 2014 (c) CountySuiie Sheriff, Telecsoft, Inc. RECEIVED JUNi 2014 0 THE COURT OF COMMON PLEAS `; CUMBERLAND COUNTY PA n = z: DAVID D. BUELL, PROTHONOTARY mz — "r-' One Courthouse Square • Suite100 • Carlisle, PA • 17014 'r'` 240-6195 "' -a 0 .<- (717) = Pi www.ccpa.net moo, ry 0 x Q _, -D co > WEST SHORE COUNTRY CLUBSJ:21161-(-0 gOl Vs. NO 13-2188 Civil Term CIVIL ACTION — LAW LISA M. BROSIUS WRIT OF EXECUTION (Pa R.C.P. 3252) TO THE SHERIFF OF YORK COUNTY: To satisfy the judgment, interest and costs against LISA M. BROSIUS, 801 W. SIDDONSBURG ROAD, DILLSBURG, PA 17019 Defendant (s) (1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein; LEVY UPON ALL PERSONAL PROPERTY OF THE ABOVE -LISTED DEFENDANT(S) ABOVE ADDRESS IN YORK COUNTY, INCLUDING BUT NOT LIMITED TO FURNI' 1R.E, JEWELRY, ELECTRONICS, SUPPLIES, ETC.. odd; (2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of GARNISHEE(S), as garnishee, (Specifically describe property) and to notify the garnishee that 24 n, (a) an attachment has been issued; .? rn -71 (b) except as provided in paragraph (c), the garnishee is enjoined from paying any debt to or for the accouiWbf the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (c) the attachment shall not include (i) the first $10,000 of each account of the defendant (s) with a bank or other financial institution containing any funds which are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (ii) each account of the defendant (s) with a bank or other financial institution in which funds on deposit exceed $10,000.00 at any time if all funds are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (iii) any funds in an account of the defendant (s) with a bank or other financial institution that total $300 or less. If multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as determined by the executing officer. The funds shall be set aside pursuant to the defendant (s) general exemption provided in 42 Pa.C.S. § 8123. (3) if property of the defendant (s) not levied upon and subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify such other person that he or she has been added as a garnishee and is enjoined as above stated. Amount Due $4,320.98 Plaintiff Paid Interest FROM JDMT TO 5/8/14 - $.71 PER DIEM - $238.66 Law Library Attorney's Comm. 5 % STATUTORY RATE - $216.05 Due Prothonotary $2.25 Attorney Paid $287.11 Date: 5/30/14 t"5e ) Other Costs bii h'ALusti. David D. Buell, Prothonotary By: REQUESTING PARTY: Name : JEFFREY L. TROUTMAN, ESQUIRE Address: KODAK LAW OFFICES, P.C. 407 NORTH FRONT STREET, 3RD FLOOR HARRISBURG, PA 17101. Attorney for: PLAINTIFF Telephone: 717-238-7159 Supreme Court ID No. TRUE COPY FROM RECORD In Tc-'ir any whereof, I here unto set my hand and of said Court at Carlisle, Pa.y,� day of— rn�,-'20_._1— Prothonotary MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain insurance proceeds 8. Such other exemptions as may be provided by law Cc - 91:01 WV 61 NIThIQZ 2 WEST SHORE COUNTY CLUB Plaintiff V LISA M. BROSIUS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2013-2188 CIVIL Defendant(s) CIVIL ACTION - LAW PRAECIPE TO THE PROTHONOTARY: Please Satisfy Judgment and Discontinue Case. Dated: July 3, 2014 J f ` =y i. Troutman, Esquire for Robert D. Kodak, Esquire Attorney for Plaintiff Attorney I.D. No. 53984